F. H. E. Oil Co. v. Helvering

This case presents the same issue as is involved in Helvering v. Wilshire Oil Co., ante, p. 90, except that it arises under the Revenue Act of 1932 (47 Stat. 169). In computing its taxable net income under that Act, petitioner deducted certain development expenditures as it had done since its organization in 1925. But it refused to take these same deductions in computing net income for the purpose of applying the 50 per cent limitation on the depletion allowance, as provided in §,114 (b) (3) of the 1932 Act. 1 That section, so far as material here, was the same as § 114 (b) (3) of the 1928…